
A noted anti-betting campaigner, who has been part of the government’s advisory board for the revamped Gambling Act legislation, has quit in opposition of the proposed roll-out of affordability checks.
James Noyes, who has been a prominent figure on the Gambling Act Review Evaluation Advisory Group, has described the ‘unacceptable’ situation of the financial risk assessments being approved despite being unscrutinised by anybody but the Gambling Commission.
He revealed that the government’s wish to sign off on the scheme, despite not having performed ‘meaningful evaluation’ of the findings of the regulator’s pilot study, forced him to resign from the panel.
Clearly Unacceptable

Noyes is an interesting commentator on the introduction of affordability checks.
He is of an anti-gambling stance and was one of the first notable voices to call for the implementation of financial checks on big spending punters. Noyes has also written extensively about the need to raise gambling taxes, which of course was the outcome of the chancellor’s Autumn Budget in November.
A dedicated researcher into gambling harm and the wider sector, Dr Noyes was called up to the Gambling Act Review panel for his expertise.
But the absence of an independent testing and analysis phase of the Gambling Commission’s financial risk assessments pilot saw Noyes write an open letter to Lisa Nandy, the head of the Department of Culture, Media and Sport, calling for the roll-out to be halted.
“The current situation of financial risk checks is raising serious questions, which should be addressed by government before any further progress of that policy is made,” Noyes wrote.
“I am therefore calling on the government to pay heed to the BHA’s warnings and to pause these checks until there has been adequate evaluation and scrutiny.”
Elsewhere in the letter, Noyes admits he was ‘deeply concerned’ about the lack of transparency in the pilot process, as well as fears that the test checks were subject to ‘inconsistent data, unclear outcomes and unnecessary friction.’
Penned nearly a month ago and with no slowdown in the roll-out of affordability checks forthcoming, Noyes felt like he had no choice but to walk away.
“It astonishes me that controversial financial risk checks are being rolled out by the Gambling Commission before any meaningful evaluation of this policy can be carried out,” Noyes commented. “This is clearly unacceptable.
“The government has a duty to ensure that its legislative proposals are evaluated in an adequate manner. In the case of the Gambling Act review, and most notably financial risk assessments, this has not happened.”
Noyes’ comments have been echoed by former culture minister Stuart Andrew, who called on the government to bring financial checks ‘back to Parliament’ for further scrutiny.
Red Flags

The Gambling Commission provided periodical updates on the financial risk assessments pilot scheme, which ran for around 18 months from the summer of 2024.
Although the success rate of ‘frictionless’ checks increased as the regulator’s systems became more agile, there were still some red flags in their findings.
The Commission admitted that multiple credit agencies were providing different results for the same customer, which suggests that the checks cannot be frictionless in all cases.
Further concerns about the intrusive nature of the checks – something that the Gambling Commission has been quick to defend themselves against, have led to concerns that more punters could be lost to the black market.
Alarming research revealed that unlicensed betting sites now take £16.6 billion in bets each year – one of the reasons why the government has pledged an additional £26 million to the Gambling Commission to help tackle the rise of the illegal sector.
The introduction – or even the threat – of financial risk assessments is hardly likely to help on that front, while horse racing, which generates a huge slice of its annual revenue from the betting levy, is also likely to be seriously inconvenienced.
Estimates suggest that racing could lose as much as £13 million a year, while the Treasury could also miss out on tax income of £300 million annually.
The head of the British Horseracing Authority (BHA), Brant Dunshea, praised Noyes for taking a stand against the current state of affairs.
“We commend Dr Noyes for having the courage and principle to resign from this evaluation group over his concerns about its work,” he said.
“What increasingly appears to be an ideological desire to implement affordability checks is now impacting sound policy making.”